Picture from Humoar.com
She and her husband enjoy sailing, and have their yacht moored at a marina on the south coast. Last weekend, whilst at this marina, my friend had reason to comment to the manager about the state of the shower block. There was a build-up of mildew and suggested using bleach. “Sorry” said the manager, “Bleach is banned, so we can’t use it” so she checked this with me, and the manager is wrong. Bleach is not banned but you must follow strict controls in its use.
This question prompted me into thinking as to whether there are other businesses unsure about their duties regarding hazardous substances. Consequently I thought that I should do a COSHH update.
The two HSE cases this week both look at tragic accidents that shouldn’t have happened
- Mr Major had been helping to clear a blockage from machinery when he was dragged into the blender and killed.
- Andrew Elliss, an employee of UCH Logistics, was hit by a reversing fork-lift truck in September 2014. He sustained head injuries that continue to have an effect on him to this day.
As ever, if you have a subject that you would like us to cover one week, please contact us by phone 01458 253682, email or via our Facebook page or by Twitter.
Working with substances hazardous to health
Every year, thousands of workers are made ill by hazardous substances, contracting lung disease such as asthma, cancer and skin disease such as dermatitis. These diseases cost many millions of pounds each year to:
- industry, to replace the trained worker;
- society, in disability allowances and medicines; and
- individuals, who may lose their jobs.
You, as the employer, are responsible for taking effective measures to control exposure and protect health. These measures can also improve production or cut waste.
Looking after your business
Your aim in running your business is to make a profit. You know what you do, and how you are doing it. You know what ‘processes’ and ‘tasks’ are involved. You know the short cuts. Ensuring your workers remain healthy may also lead to healthy profits.
Myth – ‘Of course my business is safe – we’ve always done it this way.’
Reality – Some diseases take years to develop. If exposure is high because the task has always been done that way, maybe it’s time for a change.
Which substances are harmful?
- Dusty or fume-laden air can cause lung diseases, eg in welders, quarry workers or woodworkers.
- Metalworking fluids can grow bacteria and fungi which cause dermatitis and asthma.
- Flowers, bulbs, fruit and vegetables can cause dermatitis.
- Wet working, e.g. catering and cleaning, can cause dermatitis.
- Prolonged contact with wet cement in construction can lead to chemical burns and/or dermatitis.
- Benzene in crude oil can cause leukaemia.
Many other products or substances used at work can be harmful, such as paint, ink, glue, lubricant, detergent, beauty products and, of course, bleach.
Myth – ‘It’s natural so it can’t be harmful.’
Reality – Natural materials can be harmful. For example, henna can cause dermatitis and asthma, wood dust can cause asthma or even cancer, stone or concrete dust can cause lung disease such as silicosis, and citrus oils can cause skin problems.
III health caused by these substances used at work is preventable. Many substances can harm health but, used properly, they almost never do.
N.B. Substances can also have other dangerous properties. They may be flammable, for example solvent-based products may give off flammable vapour. Clouds of dust from everyday materials, such as wood dust or flour, can explode if ignited.
So what must you do?
Look at each substance
Which substances are involved? In what way are they harmful? You can find out by:
- checking information that came with the product, e.g. a safety data sheet;
- asking the supplier, sales representative and your trade association;
- looking in the trade press for health and safety information;
- checking on the Internet,
Think about the task
If the substance is harmful, how might workers be exposed? By:
- breathing in gases, fumes, mist or dust?
- contact with the skin?
- contact with the eyes?
- skin puncture?
Myth – ‘I don’t work with harmful substances.‘
Reality – Most businesses use substances that can be hazardous to health – even something as simple as flour can act as a substance hazardous to health.
Bear these in mind when you look at the tasks.
Exposure by breathing in
Once breathed in, some substances can attack the nose, throat or lungs while others get into the body through the lungs and harm other parts of the body, e.g. the liver.
Exposure by skin contact
Some substances damage skin, while others pass through it and damage other parts of the body. Skin gets contaminated:
- by direct contact with the substance, e.g. if you touch it or dip your hands in it;
- by splashing;
- by substances landing on the skin, e.g. airborne dust;
- by contact with contaminated surfaces – this includes contact with contamination inside protective gloves.
Exposure by swallowing
People transfer chemicals from their hands to their mouths by eating, smoking etc without washing first.
Exposure to the eyes
Some vapours, gases and dusts are irritating to eyes. Caustic fluid splashes can damage eyesight permanently
Exposure by skin puncture
Risks from skin puncture such as butchery or needlestick injuries are rare, but can involve infections or very harmful substances, e.g. drugs.
Safety data sheets
Products you use may be ‘dangerous for supply’. If so, they will have a label that has one or more hazard symbols.
The GHS (Globally Harmonised System) of Classification and Labelling of Chemicals became fully effective in the UK at the end of May 2015, and replaced the previous standards for marking of dangerous or hazardous substances and mixtures. So please note the changes?
Safety data sheets can be hard to understand, with little information on measures for control. This is why you must carry out a full COSHH Assessment and ensure that you and your employees know what to do if they come in contact with substances.
Assessing the risk
Risk assessment is not just a paper exercise. It’s about taking sensible steps to prevent ill health. You need to know how workers are exposed, and to how much, before you can decide if you need to do anything to reduce their exposure. The COSHH Regulations require employers to assess the risk to their employees, and to prevent or adequately control those risks. Sometimes, it’s easy to judge the amount of exposure to substances and decide what you can do about it.
When the task involves very small amounts of material, even if these are harmful, when there is little chance of it escaping, the risk is low. But the risk in a different task – such as cleaning up and disposal – will be higher because the harmful substance may be breathed in or get onto the skin.
When the task involves larger amounts of material, with obvious leaks, exposure is higher and so is the risk. Whether the substance is harmful or not, your need to control it is obvious. Decide what measures you need to take, and when.
If you have five or more employees, you must record your assessment but, even if you have fewer than five, it makes sense to write down what steps you have taken to identify the risks. And the really important part is making a list of the actions you are taking to control the risks to health.
There are numerous examples of good practice available on the web. However, there may be no ‘good practice’ advice available for your process. Where this is small-scale with obvious control measures, you can do the assessment yourself.
In other cases, or where you are not sure, ask your supplier, trade association or other reliable information sources. You may need professional advice such as from the Wilkins Safety Group.
Myth – ‘What do you expect – it’s a dirty job!’
Reality – Why does your job need to be dirty? Think about changing the way you work to produce cleaner processes.
What are exposure control measures?
Control measures are always a mixture of equipment and ways of working to reduce exposure. The right combination is crucial. No measures, however practical, can work unless they are used properly.
So any ‘standard operating procedure’ should combine the right equipment with the right way of working. This means instructing, training and supervising the workers doing the tasks.
You need control measures that work and continue to work – all day, every day.
Examples of control measures
|Substance. Process||Control equipment||Way of working||Managing|
- Cleaning with solvent on rag.
- Use a rag holder.
- Provide a small bin with a lid for used rags.
- Avoid skin contact.
- Reduce solvent vapour from used rags.
- Check controls are used.
- Safe disposal.
- Dust and sparks from abrasive wheel.
- Put an enclosure around the wheel and extract the air to a safe place.
- Check the airflow indicator.
- Make sure the extraction works.
- Maintain controls.
- Test controls as required by law.
- Fume from cutting demolition scrap.
- Ventilated welding helmet, gloves.
- Washing facilities.
- Work outdoors upwind of the fume wherever possible.
- Allow the fume to clear before removing helmet.
- Check if there is any lead paint on the scrap being cut.
- Carry out health checks.
- Cutting-fluid mist from a lathe.
- Put an enclosure around the lathe and extract the air to a safe place.
- Protective gloves.
- Use skin-care products.
- Make sure the extraction works.
- Allow time for the mist to clear from the enclosure before opening it.
- Train workers.
- Check and maintain fluid quality.
- Test controls as required by law.
- Carry out health checks.
- Dust from disc cutter on stone worktop.
- Use an enclosure to extract air to a safe place.
- High-efficiency vacuum cleaner.
- Cut and polish worktops inside an enclosure.
- Vacuum up dust.
- Test and maintain controls.
- Carry out health checks.
Myth – ‘They wouldn’t sell it to us if it wasn’t safe.’
Reality – Just because something is available to buy, does not mean it is safe – you can buy cyanide for industrial use.
Choosing control measures
In order of priority:
- Eliminate the use of a harmful product or substance and use a safer one.
- Use a safer form of the product, eg paste rather than powder.
- Change the process to emit less of the substance.
- Enclose the process so that the product does not escape.
- Extract emissions of the substance near the source.
- Have as few workers in harm’s way as possible.
- Provide personal protective equipment (PPE) such as gloves, coveralls and a respirator. PPE must fit the wearer.
If your control measures include 5, 6 and 7, make sure they all work together.
Control equipment comes in many forms. It includes ventilation to extract dust, mist and fume; glove boxes and fume cupboards; spray booths and refuges (clean rooms in dirty work areas). It also includes using water to reduce dust, and systems for disinfecting cooling water.
For control equipment, your supplier should provide a ‘user manual’. If you don’t have one, ask for it. And if this is impossible, you may need professional help to write one. The user manual should set out schedules for checks, maintenance and parts replacement. For example it should include:
- a description of the system;
- the daily checks the worker or supervisor needs to carry out, e.g. the ventilation is turned on, the airflow indicator gives the right reading;
- the weekly or monthly checks the supervisor or owner needs to carry out, e.g. of equipment wear and tear, and that short cuts are not creating dangers;
- details of any thorough examination and test;
- signs of wear and control failure;
- a list of replaceable parts;
- a description of how operators should use the system so it works effectively.
Remedy defects in good time. It is pointless making checks if you take no action when something is wrong. And you are not managing health and safety properly if the ‘thorough examination and test’ produces a long list of ‘actions needed’.
Keep simple records of your checks and actions, eg in a logbook, and keep these records for at least five years.
Myth – ‘I’ve given them all masks – problem solved!’
Reality – This won’t solve it. Control the source of exposure and then they might not need masks.
Staying in control: Checking and maintaining
Once you’ve got control, you need to keep it. As the employer, you must make sure that the control measures (equipment and the way of working) keep working properly.
You should name someone to be in charge of checking and maintaining control measures. It could be you, or someone you appoint, as long as they know what they need to do, and are able to do it. That is, they are ‘competent’ to:
- check that the process isn’t emitting uncontrolled contaminants;
- check that the control equipment continues to work as it was designed;
- check that workers follow the right way of working.
Two of the most common control measures where maintenance is critical are local exhaust ventilation (LEV) and personal protective equipment (PPE).
Local exhaust ventilation (LEV)
If you use local exhaust ventilation to control exposure, it needs regular checking and thorough examination and testing at least once every 14 months or at more frequent intervals if you are using it with one of the processes listed in Schedule 4 of COSHH.
Many people, e.g. engineers or insurance companies can carry out thorough examination and testing of LEV. Whoever does the work must be competent
Personal protective equipment (PPE)
Personal protective equipment is often used as part of control measures. This also needs checking and maintenance because, if it fails, it no longer provides protection and exposes the wearer to danger. The users need to know exactly what they are doing, and so do the supervisors.
Skills and experience
Ensure that whoever designs, installs, maintains and tests your control measures is competent – they have the necessary skills, knowledge and experience. You can assess the competence of equipment and service providers with questions such as:
- Have you done this sort of work before?
- What are your qualifications?
- Do you belong to a professional organisation?
- Can I speak to previous clients?
Ideally, you want someone who knows your industry, has a successful track record, and gives good value for money.
Involve your workers in developing control measures to make sure they are suitable for the way they carry out the work. Encourage them to suggest improvements, and to report anything they think might be going wrong.
Training, instruction and information
Explain to your workers, and anyone else who needs to know, what the dangers are. It is poor practice just to hand them a page of written information.
- Show workers how to use control measures properly, and how to check that they are working.
- Carry out practice drills for cleaning up spills safely – do this before any spillages happen.
- If workers need to use respirators, they also need face fitting and training.
- If they need to use protective gloves, they need to know how to put them on and take them off without contaminating their skin.
Keeping workers healthy
Monitoring normally means air sampling but it may also involve taking biological samples, e.g. breath or urine. Monitoring normally makes reference to ‘Workplace Exposure Limits’ (WELs) published by HSE. These limits should not be exceeded.
If your trade press, HSE, or other information, shows there is a problem with health in your trade, such as asthma or dermatitis, your employees may need special health checks. The most common checks are for respiratory disease such as asthma and skin disease.
REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of CHemicals. It came into force on 1 June 2007 and replaces a number of European Directives and Regulations with a single system.
REACH will operate alongside COSHH and is designed so that better information on the hazards of chemicals and how to use them safely will be passed down the supply chain by chemical manufacturers and importers through improved safety data sheets.
If you would like further help on this topic or if you have any topic you would like us to cover in this newsletter please contact us by phone 01458 253682 or email.
We are running the following courses:
FIRST-AID AT WORK 3-DAY COURSE
All employers in the UK have a legal obligation to make first aid provision for their employees. This course is ideal for those who are going to be a nominated First Aider in the workplace. This three day course meets the statutory requirements of the Health & Safety Executive. Candidates must be of a working age and intend to practice first aid in the workplace during the validity of the certificate.
Who Is This Course Suitable For?
- Smaller companies
- Offices and shops with less than 50 employees and other low risk environments
- Employees working off site
- Self-employed people
- Anyone who wants to learn first aid and assist in an emergency situation.
- Health & Safety Responsibilities
- Managing an Incident
- Priorities of First Aid
- Managing an Unconscious Casualty
- Cardiopulmonary Resuscitation
- Low Blood Sugar
- Head Injuries
- Chest Pains
- Eye Injuries
- Injuries to bones, muscles and joints
- Burns & Scalds
- Moving Casualties
- Poisons, Gases & Fumes
- Care and Communication
Course Duration: 3 Days
COURSE REF DATE(s) LOCATION
WSG. FA . 1501 28th /29th /30th October 2015 Taunton Racecourse
Fee: £360 to include Course notes, mid-morning & afternoon refreshments, Finger buffet lunch on each day and a Certificate of Training (Fee subject to VAT)[/fusion_text]
CDM Regulations 2015 – The Management of Pre-Construction Health and Safety
Course Objective – Training /CPD and APS Certificates issued
This 3 day course, which is accredited by the APS, is aimed at all CDM 2015 duty holders and those involved in construction planning, design and management. It has been developed to guide you through the regulatory requirements and practical implementation of the Construction (Design & Management) Regulations 2015.
The course has been designed to advise Clients, Principal Designers, Designers, Principal Contractors and contractors on how they can ensure compliance with CDM 2015. It focuses on the duty holder roles for application of the regulations to construction projects in the Pre-Construction Phase. It is also aimed at construction safety professionals and CDM Advisors, Project Managers, Facilities Managers and any other construction professionals that have a duty to comply with CDM 2015
- Historical background for changes
- Client Duties and Domestic Clients
- Principal Designer Duties
- Principal Contractor Duties
- Expectations of the HSE
- CDM Documentation
Benefits of Attending
You will have an insight into the intentions and implications of CDM 2015 for duty holders in the Pre-Construction Phase and the detailed requirements for discharging health and safety coordination duties.
An individual who successfully completes this CDM2015 Awareness Course may claim points towards membership of the Association for Project Safety – APS
Course Duration: 3 days (1 day a week for 3 weeks)
COURSE REF DATE(s) LOCATION
CDM2015/3 1501 Tuesdays 3rd/10th/17th November 2015 Taunton Racecourse
Fee: £660 to include Course notes, exams, mid-morning & afternoon refreshments, a buffet lunch on each day and the appropriate Certificate of Training (Fee subject to VAT).
For more information and to book and pay on line please visit our training page.
If you have any questions about these courses or any other training or would like us to run a particular course for you, call Jon Wilkins of the Wilkins Safety Group on 01458 253682 or email him.
Your Business is Safer in our Hands